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Intellectual Ventures I v. Capital One

Representative Claim

‘081

21. An apparatus for manipulating XML documents, comprising:

a processor;

a component that organizes data components of one or more XML documents into data objects;

a component that identifies a plurality of primary record types for the XML documents;

a component that maps the data components of each data object to one of the plurality of `primary record types;

a component that organizes the instances of the plurality of primary record types into a hierarchy to form a management record type;

a component that defines a dynamic document for display of an instance of a management record type through a user interface; and

a component [**14]  that detects modification of the data in the dynamic document via the user interface, and in response thereto modifies a data component in an XML document.

Posture:

Appeal from the United States District Court for the District of Maryland in No. 8:14-cv-00111-PWG

Abstract Idea: Yes

[Analysis of the ‘002 patent is located in the companion appeal. See Intellectual Ventures I LLC v. Erie Indemnity Co., Nos. 2015-1128, -1129, -1132, 850 F.3d 1315 (Fed. Cir. March 7, 2017) (affirming the district court’s dismissal under Rule 12 for reciting patent-ineligible subject matter).]

The Federal Circuit agreed with the lower court that the ‘081 patent constituted an abstract idea.

“Although IV correctly observes that the ‘081 patent applies to XML documents in particular (rather than any other type of document), at best, this limits the invention to a technological environment for which to apply the underlying abstract concept. But such limitations do not make an abstract concept any less abstract under step one. Intellectual Ventures I, 792 F.3d at 1366. As the specification recognizes, companies have frequently employed XML documents in routine business transactions. ‘081 patent col. 1 ll. 28-36. Thus, the patent’s recitation of XML documents specifically, does little more than restrict the invention’s field of use. Such limitations do not render an otherwise abstract concept any less abstract. Affinity, 838 F.3d at 1259.”

Something More: No

Nor did the ‘081 patent demonstrate an inventive concept that could transform the abstract idea into patentable subject matter.

“Although [the ‘081] patent purports to have met a need in the art to ‘allow[] the user to view and update XML documents in different formats, and . . . manipulate the data and perform actions without programming skills,’ the claims recite nothing inventive or transformative to achieve this stated goal. ‘081 patent col. 1 ll. 45-48. Thus, taken individually or in combination, the recited limitations neither improve the functions of the computer itself, nor provide specific programming, tailored software, or meaningful guidance for implementing the abstract concept. Alice, 134 S. Ct at 2359. Accordingly, they do not meaningfully limit the claims to provide the requisite inventive concept under step two.”